PUBLIC LAW 101-239—DEC. 19, 1989 103 STAT. ^361 (A) or (B), the running of any period of limitations under section 6501 (relating to assessment and collection of tax) or under section 6531 (relating to criminal prosecutions) with respect to any transaction to which the summons relates shall be suspended for the period during which such proceeding, and appeals therein, are pending. In no event shall any such period expire before the 90th day after the day on which there is a final determination in such proceed- mg. (e) EFFECTIVE DATE. —The amendments made by this section shall 26 USC 6038A apply to taxable years beginning after July 10, 1989. ^****- SEC. 7404. REPEAL OF SPECIAL TREATMENT OF INTEREST ON CERTAIN FOREIGN LOANS. v (a) GENERAL RULE.— Paragraph (2) of section 1201(e) of the Tax Reform Act of 1986 is hereby repealed. 26 USC 904 note. (b) EFFECTIVE DATE. —The repeal made by subsection (a) shall 26 USC 904 note, apply to taxable years beginning after December 31, 1989. (c) EXCEPTION FOR CERTAIN TAXPAYERS WITH SUBSTANTIAL LOAN 26 USC 904 note. Loss RESERVES. — (1) IN GENERAL.—The repeal made by subsection (a) shall not apply to any taxpayer if, on any financial statement filed by ^ such taxpayer for regulatory purposes with respect to any quarter ending during the period beginning on March 31, 1989, and ending on December 31, 1989, such taxpayer showed loss reserves against its qualified loans equal to at least 25 percent of the amount of such loans. (2) DEFINITIONS AND SPECIAL RUL^S.— For purposes of this subsection— (A) QUALIFIED LOAN.— The term "qualified loan" has the meaning given such term by section 1201(e)(2)(H) of the Tax Reform Act of 1986 (as in effect before its repeal by subsec- tion (a)). ^ (B) PARENT-SUBSIDIARY CONTROLLED GROUPS. —In the case of any taxpayer which is a member of a parent-subsidiary ei;^. controlled group (as defined in section 585(c)(5)(A)), this subsection shall be applied by treating all members of such f group as 1 taxpayer. Subtitle E—Excise Tax Provisions SEC. 7501. 1 -YEAR SUSPENSION OF AUTOMATIC REDUCTION IN AVIATION- RELATED TAXES. (a) IN GENERAL. —Subsection (a) of section 4283 (relating to reduc- tion in aviation-related taxes in certain cases) is amended by strik- ing "1990" and inserting "1991". (b) CONFORMING AMENDMENTS. — (1) Clause (i) of section 4283(b)(l)(A) is amended by striking "1988 and 1989" and inserting "1989 and 1990". (2) Paragraph (3) of section 4283(b) is amended— (A) by striking "1990" and inserting "1991", and (B) by striking "1989" and inserting "1990". (3) Subsection (q) of section 6427 is amended by striking "1990" each place it appears and inserting "1991".
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